Three key sales executives of Oracle Singapore were dismissed recently under hushed proceedings, following charges of fraudulent conduct, sources said.

The trio started a company in their wives' names, and registered the local firm as a certified Oracle reseller. But over time, talk that these employees were siphoning off orders to one particular reseller could no longer be ignored.

The rumblings got louder and an investigation into the matter was launched. According to the sources, the inquiry took several months and apart from internal investigators and lawyers, it was learned that Singapore's Corrupt Practices Investigation Bureau assisted in the case.

When the case was concluded in November, Oracle found the employees guilty of gross misconduct. "Yes, they were terminated," said Oracle South Asia regional managing director Keith Budge.

"This is not the first time we've taken disciplinary action against our employees," Budge said in an interview. He declined to name the guilty parties nor comment further due to legal implications.

Following the incident, Oracle's 6,800 employees in Asia-Pacific were served a Disclosure of Interests Policy memo via email on November 14. The company's legal department outlined several guidelines on how to avoid conflicts of interest, and required all employees to declare their share in its subsidiaries or partners.

When it comes to resellers, background checks may not be as intensive but Oracle has a procedure in place.

According to Frank Koo, Oracle Singapore Channels and Alliances senior director, the company vets each reseller before accepting them.

"We contact the Registry of Companies and Businesses (RCB) to ensure that these companies exist and are financially worthy," he said in a separate interview.

Oracle is also aware of each resellers' shareholding structure as the RCB provides such information, Koo said.

In the memo, Michael Wilde, Oracle Corp general counsel and vice president (Legal), urged employees to disclose any business interests so as to avoid "the suggestion of improper behaviour".

"Conflicts of interest situations may arise in many ways," Wilde wrote in the e-mail, providing the following as examples: * Employment by a competitor, regardless of the nature of the employment whilst employed by Oracle; * Placing business with (including making purchases from) a firm in which an Oracle employee, his or her family or any close personal associate have a substantial ownership interest or derive some financial or other benefit; * Ownership of or substantial interest in a company which is a competitor with or a supplier of Oracle; and * Acting independently as a consultant to an Oracle customer or supplier.

In a copy of the memo, Wilde said that the appearance of a conflict of interest can easily arise although there was no actual improper behaviour. "All Oracle employees are encouraged to conduct themselves in a manner that avoids even the appearance of a conflict between their personal interests and the interests of the company."

For instance, by identifying that you have shares in a company run by a close relative, and that company is a member of the Oracle Partner Network receiving commissions which are paid following referrals, you avoid suggestions of impropriety, Wilde said.

"This is also so others within Oracle can verify that the business relationship is commercially proper, and that your interest in the partner company is not in conflict," he added.

Senior management, including vice-presidents, line of business (LOB) heads, financial controllers, company directors and officers of an Oracle subsidiary, are required to complete Oracle's Disclosure of Interests form, Wilde said, regardless of whether there was anything to declare.

Additionally, employees with an expenditure authorization of more than $5,000 (£3,515) per annum, and those involved in recommending the acquisition of supplies above $10,000 per year are also required to disclose their interests.

Wilde did not say what action would be taken if an employee was found guilty for breach of conduct.

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